Ezel / IRS Rulings / 200952047

CCA 200952047: No CDP notice is required for a lien arising under IRC section 6324

Number
200952047
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Estate Tax Liens
Topics
Procedure, penalties, and administration
Code sections
§ 6320, § 6324
Ruling dated
November 19, 2009
Publicly released
December 25, 2009
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2009, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2009
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

Chief Counsel Advice addresses whether a collection due process notice must be sent for a particular lien. It concludes that no CDP notice is required because IRC section 6320 does not apply to liens that arise under IRC section 6324.

Ruling snapshot

  • Question: Must a CDP notice be sent for a lien arising under IRC section 6324?
  • Outcome: Advice given
  • Key authorities: IRC §§ 6320 and 6324

Full text (IRS public release)

ID: CCA_2009111911542047 Number: 200952047
Release Date: 12/24/2009
Office:
UILC: 6324.01-00

From: -----------------------
Sent: Thursday, November 19, 2009 11:55:13 AM
To: --------------------------
Cc: ----------------------------------------------
Subject: RE: Question

--------------

A CDP notice does not have to be sent in this case because I.R.C. § 6320 does not apply to liens that
arise under I.R.C. § 6324.

Please let me know if you have any additional questions.

Thanks!

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